Category Archives: audit

While not a complicated or strategic topic that I would normally highlight, this one bit of news is from my home airport and personally meaningful.

Basically the report shows that 1,600 badges were lost or stolen in a 2 year period. This seems like a big number (2.6%), but this is a control that should (and not highlighted in broadcast) secondary supportive controls, such as:

Analytics on badge entries against the work shifts of the person assigned

Access to areas not zoned for that worker

Termination of employees who don’t report in 12 hours on lost/missing badge

There are safeguards highlighted in broadcast that are good, but easily modified to the point of not being any value, and include:

Pin (can be easily observed due to tones and no covering)

Picture (every movie ever shows how easy this is done)

An old badge could be re-programmed and be a duplicate of another higher ranking / alternate security zone

Bottom line is organizations, especially those tasked with safety of human life, must have the primary and secondary controls in place. Hopefully the remarks of a minor risk are based on their security assessments with the considerations above (and more perhaps).

Article:
Hundreds of ID badges that let airport workers roam the nation’s busiest hub have been stolen or lost in the last two years, an NBC News investigation has found.

While experts say the missing tags are a source of concern because they could fall into the wrong hands, officials at Hartsfield-Jackson Atlanta International Airport insist they don’t pose “a significant security threat.”

Github is an awesome repository system that is very popular. Basically if you want to work on something (code, a book, electronic files) and then allow others to freely make suggested modifications (think track changes in a Microsoft Word doc), GitHub is the new way of life. I have used on publishing a book, writing code, taking a Python course online, and others are using it at a scale to produce some of the fantastic tools you see online.

I recently saw a post (included below) that clarified how their encryption was setup. Basically encryption allows you to confidentially send data to another party without the fear of others intercepting, stealing, or modifying it. It appears though that for foo.GitHub.io they are presenting the appearance of encryption, but in fact do not have it. Meaning the actual files are sent in the clear.

This is a problem in our structure of security and compliance. Today we have regulations and industry standards that are designed to prescribe specific security safeguards and levels to ensure a baseline amount of security. If organizations don’t meet the true intent of the regulations, do only enough to pass inspection, but create an environment that is susceptible to basic attacks – the user (you and me) are the one’s who suffer.

While it is disappointing for an organization to setup something that clearly creates false trust and checks a box, it is more a call to action for those who operate these systems to embrace pride of the services they are delivering. Much as Steve Jobs desired the insides and outsides of a system to be done correct – the security of an organization should not just look but be right.

We must do better as owners, operators, and security professionals. Trust depends on indicators and expectations being met, and to violate that begs the question… what else is being done in the same manner?

“cben” comment below on github.com issues post:

Turns out there is no end-to-end security even with foo.github.io domain. Got this response from GH support (emphasis mine):

[…opening commentary removed…]

While HTTPS requests may appear to work, our CDN provider is adding and removing the encryption at their end, and then the request is transmitted over the open internet from our CDN provider to our GitHub Pages infrastructure, creating the appearance of trustability.

This is why we do not yet officially support HTTPS for GitHub Pages. We definitely appreciate the feedback and I’ll add a +1 to this item on out internal Feature Request List.

A new study was released by Branden Williams and the Merchants Acquirer Committee (MAC), and it is worth a read. One aspect that jumped to me is the percentage of compliance vs compliant rates shared in the study. The difference here is those who have represented being PCI Compliant through Attestations of Compliance (AOC) vs. those who have had their programs pressure tested by the criminals of the world, and been found wanting.

Here is the snippet from PCI GURU that highlights this state of discrepancy:

The biggest finding of the study and what most people are pointing to is the low compliance percentages across the MAC members’ merchants. Level 1, 2 and 3 merchants are only compliant around 67% to 69% of the time during their assessments. However, most troubling is that Level 4 merchants are only 39% compliant.

Depending on the merchant level, these figures are not even close to what Visa last reported back in 2011. Back then, Visa was stating that 98% of Level 1 merchants were reported as compliant. Level 2 merchants were reported to be at 91% compliance. Level 3 merchants were reported at 57% compliance. As is Visa’s practice, it only reported that Level 4 merchants were at a “moderate” level of compliance.

Board of Directors, CISO, and legal should all care deeply that PCI (and of course and certainly other contractual agreements) security is achieved honestly. To often organizations view this like registering a car with the government. This is far to complex and impactful to people within and outside a given business. The cyber economic connections between proper, efficient, and effective security all lend to better products in the market and more focus on what the business is driving towards.

Is your program honestly secure and fully addressing these least practice principles?

“Major developments with Big Data, Cloud, Mobile, and Social media” – the context and reality here is cavernous.. “

My analysis and near-random break down of this tweet are as follows with quotes pulled from the panel.

First off – be aware that these key phrases / buzz words mean different things to different departments and from each level (strategic executives through tactical teams). Big Data analytics may not be a backend operational pursuit, but a revenue generating front end activity (such as executed by WalMart). These different instantiations are likely happening at different levels with varied visibility across the organization.

“Owning” the IT infrastructure is not a control to prevent the different groups from launching to these other ‘Major developments’.

The cost effectiveness of the platforms designed to serve businesses (i.e., Heroku, Puppet Labs, AWS, etc…) is what is defining the new cost structure. CIO and CISO must

>The cloud is not cheaper if it does have any controls. This creates a risk of the data being lost due to “no controls” – highlighted by Melanie from the panel. <– I don’t believe this statement is generally true and generally FUD.

Specifically – There is a service level expectation by cloud service providers to compensate for the lack of audit ability those “controls”. There are motions to provide a level of assurance to these cloud providers beyond the ancient method established through ‘right to audit‘.

A method of approaching these challenging trends, specifically Big Data, below as highlighted by one of the CISO (apologies missed his name) w/ my additions:

Data flow mapping is a key to providing efficient and positive ‘build it’ product development. It helps understand what matters (to support and have it operational), but also see if anything is breaking as a result.

Two observations impacting the CISO and information technology organization include:

The Board is starting to become aware and seeking to see how information security is woven within ERM

Budgets are not getting bigger, and likely shrinking due to expectations of productivity gains / efficiency / cloud / etc…

Rationalization on direction, controls, security responses, must be be fast for making decisions and executing…

Your ability to get things done has little do with YOU doing things, but getting others to do things. Enabling, partnering, and teaming is what makes the business move. CIO and CISO must create positive build-it inertia.

Support and partner with the “middle management” the API of the business if you will.

We to often focus on “getting to the board” and deploying / securing the “end points” .. Those end points are the USERS and between them and the Board are your API to achieving your personal objectives.

Vendor Management vs procurement of yester-year

Acquiring the technology and services must be done through a renewed and redeveloped vendor management program. The current procurement team’s competencies are inadequate and lacking the toolsets to ensure these providers are meeting the existing threats. To be a risk adaptive organization you must tackle these vendors with renewed. Buying the cheapest parts and service today does not mean what it meant 10 years ago. Today the copied Cisco router alternative that was reverse engineered lacks an impressive amount of problems immediately after acquisition. Buying is easy – it is the operational continuance that is difficult. This is highlighted by the 10,000+ vulnerabilities that exist with networked devices that will never be updated within corporations that must have their risks mitigated, at a very high and constant cost.

The advent of user created, managed and handled passwords as the sole means of authenticating is coming to an end. The utility of these was defined in an era based on assumptions of brute force capability, system computing power and pro-active security teams. – After much debate and analysis … there is the thesis

This topic came up for me last year as I was working through some large amorphous business processes. The question of credentials was raised, and we challenged it. This is interesting as we had some pretty serious brains in the room from the house of auditing, security, risk, and business leaders. I am sharing my thoughts here to seek input and additional alternate perspectives – seeking more ‘serious brains’.

I will update as feedback comes in … this and other posts will serve as workspaces to share the analysis and perspectives to consider. I am breaking this topic across different posts to allow for edits and pointed (critical perhaps) feedback on a topic basis. This is LIVE research, so understand impressions today may change tomorrow based on information and insight. Looking forward to collaborating, and with that … lets jump right in!

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Passwords are designed to restrict access by establishing confirmation that the entity accessing the system is in-fact authorized. This is achieved by authenticating that user. Passwords / pass phrases have been the ready steady tool. The challenges to this once golden child cross the entire sphere, and I’ll be seeking your collaboration through the journey up to my RSA presentation in SFO at the end of February 2013!

False premise three – Password control objectives are disassociated from the origination and intent

FALSE PREMISE ONE: (Updated Jan.31.2013)

Passwords are great because they are difficult to break?

The idea here is that users are trained (continuously) to use complex, difficult, long, and unique passwords. The concept was that these attributes made it difficult for a password to be broken.

Lets explore what that meant… When a password was X characters long using Y variety of symbols it would take a computer Z time to break it. Pretty straight forward. (This example drawn is for a password hash that is being brute force attacked offline) This analogy and logic is also true with encryption, but it is based on poor premise:

Password cracking CPU cycles for a single machine are far more powerful than yesteryear, AND if we focus ONLY only on computing power, well the use of Cloud Armies to attack represent the new advantage for the cracking team

Password cracking by comparison pretty much made the CPU argument (and length of time to hack) moot. There exists databases FULL of every single password hash (for each type of encryption / hash approach) that can be compared against recovered passwords – think 2 excel tables .. search for hash in column A and find real world password in column B.

Interesting selective supporting facts:

A $3000 computer running appropriate algorithms can make 33 billion password guesses every second with a tool such as whitepixel

A researcher from Carnegie Mellon developed an algorithm designed for cracking long passwords that are made up of combined set of words in a phrase (a common best practice advice) – “Rao’s algorithm makes guesses by combining words and phrases from password-cracking databases into grammatically correct phrases.” This is research is being presented in San Antonio at the “Conference on Data and Application Security & Privacy” – New Scientist

“The 31-page proposal addresses how social media impacts compliance and legal risk, operational risk, reputational risk, and an increased risk of harm to consumers. While the agencies note that no additional regulations apply to social media, the relatively casual communication channels are not exempt from the rules, either.

According to the proposal, social media risk management programs should include a governance structure that includes how social media contributes to strategic goals, policies and procedures, third party due diligence, employee training, oversight, audit and compliance functions, and a reporting process.” – reference

Considering the velocity of the risks in this area and the lagging of legislation, it is fair to say that those even OUTSIDE the purview of the FFIEC, should strongly consider these as inputs to their compliance and security programs.

“The FFIEC invites comments on any aspect of the proposed guidance. It is specifically seeking comments on the following questions:

Are there other types of social media, or ways in which financial institutions are using social media, that are not included in the proposed guidance but that should be included?

Are there other consumer protection laws, regulations, policies or concerns that may be implicated by financial institutions’ use of social media that are not discussed in the proposed guidance but that should be discussed?

Are there any technological or other impediments to financial institutions’ compliance with applicable laws, regulations, and policies when using social media of which the Agencies should be aware?”

The security compliance program of an enterprise is a core function in the achievement of sales, maintaining regulatory and contractual obligations, meeting the security challenges in a connected world, and achieving a balance of consistent operations while returning a profit for the business. A challenge within these programs, and especially for businesses do that do not have a consolidated mature program operating at the executive level is the transparency of cost and improvement of margins within operations.

Transparency of cost relates to the costs of supporting compliance, security, and privacy requirements within products and services. The lack of transparency can exist in many areas, but this article focuses on the specific costs related to reporting to third parties on the state of the compliance and security program. Cost of such can exist in any of the following scenarios:

Sales person seeking to close a sale brings onboard an engineer and product manager to speak to / commit on security and regulation safeguards. Such initiation of new agreements may require a 250+ questionnaire to be completed by such an engineer that typically requires additional parties to respond – resulting in roughly 30-50 hours of engineer time x % of new deals signed annually)

The end result of this singular area of cost is time taken from valuable engineers away from developing product, improving product, and executives focused on tactical activities. In addition, a non-optimized security compliance program does not gain any leverage by the above activities, so each activity is repeating past work. Zero scale is achieved.

Reflecting on your organization, improvements can be gained. An attribute that has proven beneficial is to consider the following that easily measurable and can be tracked:

What is the unique number of security and compliance controls deployed within the products & services?

What is the number of queries for each period?

What is the number of FTE hours to address these queries? (the above are averages that I have seen, but analysis is worth refreshing for your organization)

What is the number of interactions the individuals have with the customers?

What is the current central approach to meeting the needs and responding to such queries?

The last question is leading to the idea that the program should be centralized in a manner to manage these questions centrally. This provides scale, lessons learned, and coordination across the business. The program itself when designed and tracked in such a manner becomes part of the sales process, account maintenance, and a regular touch point for the customer. Establishing the proper executive leadership and integrating this program is critical to every direct to consumer business, and more so for the rapidly growing technology services sector.